(1) Petitioner properly presented thirteen claims of constitutional
violations and sub-issues to each state court including the Michigan
Supreme Court, the Federal District Court erroneously concluded that
eleven of the thirteen claims were procedurally defaulted because of
unexhaustion for the failure to present claims to the Michigan Supreme
Court.

(1a) Did the Federal Court of Appeals review the district court's procedural
default ruling de novo as required by U.S.C. § 2254, or Cvijetinovic
v. Eberlin, 617 F.3d 833, 836 (6th Cir. 2010) , Douglas v. Alabama, 380
U.S. 415, 422, 85 S.Ct. 1074, 13 L.Ed 2d 934 (1965) and was the state
procedural rule adequate to stop habeas review?

(1b) "A state rule must be clear, consistently applied and well established
at the time of petitioner 's purported default.'* Ford v. Georgia, 498
U.S. 411, 423, 111 S.Ct. 850, 112 L.Ed 2d 935 (1991) . Can this
Honorable Supreme Court review the district court's ruling?

(2) Ihe federal district, court refused, to review the claim of actual
innocence , stating that the claim was not cognizable because it was a
freestanding claim that did not claim any other independant
constitutional violation, are claims of 'newly discovered evidence and
ineffective assistance of counsel ' claims independant claims?

(2a) Was the citing of Schulp v. Delo, 513 U.S. 298, 115 S.Ct. 851, 130
L.Ed. 2d 808 (1995) insufficient to claim an indepedant constitutional
violation?

(3) Could the claims of ineffective assistance of counsel , and newly
discovered evidence , and actual innocence claims have served to excuse
the 'cause and prejudice ' requirement of the inaccurate procedural
default bar the court impermissibly imposed? Murray v. Carrier 477
U.S. 496, 91 L.Ed 2d 397, 106 S.Ct. 2639 (1986) .

(4) Trial counsel failed to properly preserve the claims of Prosecutorial
Misconduct and Improper Instructions to a deadlocked jury for review
in state court. Edwards v. Carpenter, 529 U.S. 446, 451-52, 120 S CU
1587, 146 L Ed. 2d 518 (2000) .

(4a) Was the review conducted de novo according to McAdoo v. Elo, 365 F 3d
487, 498 (6th Cir. 2004)?

(5) There is a limited class of fundamental constitutional errors so
intrinsically harmful as to require automatic reversal. United States
v. Frady, 456 U.S. 152, 170, 102 S.Ct. 1584 (1982)_ . In Michigan, any
substantial departure from the American Bar Association Standard Jury
Instruction 5.4 For Deadlocked Juries is grounds for reversable

Whether the Federal Court of Appeals properly reviewed the district court's procedural default ruling de novo and whether the state procedural rule was adequate to stop habeas review